HomeMy WebLinkAboutState of the Stormwater Utility_121
Commission Memorandum
REPORT TO: Honorable Mayor and City Commission
FROM: Craig Woolard, Public Works Director
Brian Heaston, Project Engineer
Jon Henderson, GIS Manager
Kyle Mehrens, GIS Technician SUBJECT: State of the Stormwater Utility
MEETING DATE: March 3, 2014
AGENDA ITEM TYPE: Special Presentation
KEY ISSUES AND RECOMMENDATIONS: To address the requirements of the City of Bozeman’s Montana Pollution Discharge Elimination System (MPDES) Municipal Separate Storm Sewer System (MS4) discharge permit, the City Commission in June 2012 formed a
stormwater utility and enterprise fund. This memorandum updates the Commission on the
current state of the stormwater utility and covers the following topics:
• Stormwater system asset inventory
• Stormwater system condition assessment
• MS4 permit requirements
• Stormwater management program
• Stormwater system water quality impacts
• Key policy issue introduction
In the near future, staff will return to the Commission with formal policy discussions to determine the desired level of service and utility rate assessment method.
BACKGROUND: Ordinance 1831, adopted by the Commission on June 25, 2012 created a
stormwater utility to provide funding for current and future MS4 permit activities, including
funding costs associated with inventory and analysis of the city’s stormwater system and costs for the planning, construction, and maintenance of the stormwater system. The utility was created largely in response to a MS4 permit compliance audit completed by the Department of
Environmental Quality in December 2011. The audit identified one (1) permit violation, sixteen
(16) program deficiencies, and twenty three (23) recommendations for improvement. Formation
of the stormwater utility was the first step to alleviating MS4 permit compliance issues.
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Stormwater utility funds were immediately allocated to address the MS4 permit violation
identified in the 2011 audit. The violation was a result of an inadequate Illicit Discharge
Detection and Elimination (IDDE) program which failed to identify and map all discharge points
to receiving waters, in addition to comprehensively mapping all other stormwater infrastructure.
Stormwater System Asset Inventory To eliminate the permit violation, a substantial effort to inventory all stormwater system assets
began in 2012, and is presently nearing completion. An online interactive stormwater system
map (http://gis.bozeman.net/flexviewers/stormwater/) is publicly available and provides a visual overview of the network of stormwater assets and their relationship to urban waterways that receive stormwater discharges. A hardcopy of the map is provided as an attachment to this
memo as Exhibit A. Bozeman’s stormwater asset inventory consists of:
• 3,059 Curb Inlets
• 366 Detention Basins
• 93.4 Miles of Underground Pipe
• 50 Culvert Screens
• 21.6 Miles of Receiving Waters
• 1,276 Storm Manholes
• 551 Outfalls
• 86 Sidewalk Chases
• 300 Culverts
Storm Water System Condition Assessments
Condition data has been gathered through on-site inspections of stormwater detention basins and
closed captioned television (CCTV) underground pipe inspection. A bulleted summary of the detention basin condition findings is provided below. The condition assessment form used to record deficiency attributes is attached as Exhibit B. Deficiencies were noted as either present,
or absent; the severity of deficiency was not rated. A visual map display illustrating detention
basin locations and relative deficiency values is attached with this memorandum as Exhibit C.
• 11 Detention Basins with 7-8 deficiencies.
• 73 Detention Basins with 5-6 deficiencies.
• 112 Detention Basins with 3-4 deficiencies.
• 67 Detention Basins with 0-2 deficiencies.
• 103 Detention Basins require condition assessment
As of this date, 22 miles of the city’s 93.4 miles of mapped underground stormwater piping, or
24%, has been inspected using CCTV. Stormwater pipe inspection efforts have occurred
throughout the City. Deficiencies are identified and logged during the CCTV inspection and are
given an industry standard pipe rating. CCTV footage is recorded and kept on file for future
reference. Pipes with ‘Grade 5’ ratings are generally considered too degraded for spot repair and call for full pipe replacement or rehabilitation. The 22 miles of inspected pipe were broken into
400 individual inspection segments, 35 segments, or 9%, have grade 5 ratings. A visual map
display illustrating the completed pipe condition assessment is provided as Exhibit D
MS4 Permit Requirements The City is required to develop, implement, and maintain a stormwater management program
under its federally mandated Municipal Separated Storm Sewer System (MS4) permit. The
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current MS4 permit is provided as Exhibit E and must be renewed on a 5-year cycle. To remain
in compliance and avoid permit violations or deficiencies, strict adherence to the six (6) specific
minimum control measures listed below must be completed and reported annually to the
Montana Department of Environmental Quality (DEQ).
• Public Education and Outreach on Stormwater Impacts
• Public Involvement/Participation
• Illicit Discharge Detection and Elimination
• Construction Site Stormwater Runoff Control
• Post-Construction Stormwater Management in New Development and Redevelopment
• Pollution Prevention/Good Housekeeping for Municipal Operations
Increasing pressures from DEQ through the 2011 compliance audit have indicated the need to
improve the City’s stormwater management program. Audit results are provided as Exhibit F.
The level of service of the existing utility is not currently sufficient to comprehensively address each of the six minimum control measures to the specifications required of the MS4 permit.
Level of service should be enhanced and address funding, policies, staffing, equipment, and
workflows to effectively reduce occurrence of future permit violations or deficiencies. Without
elevating the level of service the probability of future monetary penalties, additional permit
violations, continued fresh water pollution during runoff events, and persistent infrastructure-degradation remains high.
Current Stormwater Management Program:
With limited enforcement, maintenance, and capital programs, the city’s stormwater
management program is functioning at an impaired level. Mandatory program components such as public outreach methods, pollution prevention programs, and construction management
workflows require extensive development. Several program deficiencies were identified and
documented internally throughout the inventory and condition assessment process and are further
described below.
An online stormwater system story map (http://tinyurl.com/jwauwoy) is publicly available and
provides photos which are keyed to a map pane that highlights stormwater management program
issues, as well as a few positive stormwater program elements. A stormwater management
webpage has been recently developed and the Commission and public are encouraged to visit the
page (https://www.bozeman.net/Departments-(1)/Public-Works/Stormwater/Home).
Operations and Maintenance (O&M) – Current stormwater system O&M is funded through the
street maintenance district fund and performed by the Streets Department. No dedicated funding
specifically for stormwater system O&M currently exists. Based on the condition assessment
conducted to date, existing personnel and capital resources have not adequately kept pace with the maintenance requirements of the stormwater system creating a significant backlog of
deferred maintenance items such as pipe repairs/replacements, catch basin, manhole and pipeline
cleaning, and detention basin maintenance.
Construction Site Management – Continued growth and limited education and enforcement capabilities on active construction sites has resulted in the degradation of many relatively new
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stormwater system assets. The most common construction site impacts to the stormwater system
are clogged storm drain pipes and detention basin outlets which create unnecessary deferred
maintenance items for the stormwater utility had best management practices been effectively
deployed by site construction contractors.
Illicit Discharge Detection and Elimination (IDDE) – Illicit discharge events have the potential to severely threaten public safety and water quality by delivering pollutants to the stormwater
system and urban receiving waters. Detection of illicit discharges has historically occurred
passively on a complaint basis, which does not sufficiently address MS4 permit requirements. As
a result of the storm system inventory and condition assessment activities, the city was successful in identifying, responding to, and resolving 11 illicit discharge issues in 2013 as shown on Exhibit G.
Community Outreach - A successful stormwater outreach campaign has been initiated through
the development of informative materials and collaborative efforts with local non-profits
(Greater Gallatin Watershed Council, Big Sky Youth Empowerment, Gallatin Local Water Quality District, and Montana State Extension Water Quality). The public has been educated
with newspaper articles, pamphlets, trainings, participation in community events and interviews.
Dedicated staff resources are necessary to further develop and manage this program to improve
the consistency and overall effectiveness of outreach efforts in order to ensure MS4 permit
compliance.
Capital Planning – Annual pipe rehabilitation capital budgets, similar to the water and
wastewater utilities, are necessary to fund pipe replacements at a level that outpaces the present
rate of asset degradation. In addition, multiple equipment CIP items will be necessary to elevate
the level of service to tackle continued O&M and deferred maintenance items.
Stormwater System Water Quality Impacts
The overall success of the stormwater utility and its stormwater management program is
measured by increasing water quality in the city’s urban waterways. The MS4 permit is
mandated by federal law through implementation of the Clean Water Act and the permit requires bi-annual water quality testing to occur at approved sampling locations for a particular array of
pollutants of concern. Past testing data, provided as Exhibit H, indicate that the current level of
service afforded the stormwater utility (or stormwater management program prior to 2011 utility
formation) has been insufficient to reduce the frequency of exceeding MS4 permit limits for
many of the pollutants of concern. Failures to conform to water quality testing limits, or improve the level of conformance with testing limits, suggests that the level of service of the stormwater
utility should be enhanced, including significant upgrades to the city’s overall stormwater
management program.
Introduction of Key Policy Issues The stormwater asset inventory and condition assessment efforts completed post utility
formation provide a factual decision making platform that can be used to inform future policy
decisions to address identified deficiencies of the current stormwater utility and management
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program. Highlighted as follows are some interesting general findings and conclusions resulting
from of the inventory and assessment effort.
• Two separate stormwater regimes exist in the city with disparate infrastructure and maintenance needs: the ‘old’ system, and the ‘new’ system. The ‘old’ system is generally
described in geographic terms by the historic conservation overlay boundary and
represents a stormwater regime without existing treatment capabilities (ie detention
basins). The ‘old’ system infrastructure generally requires capital projects for pipe replacement and stormwater treatment retrofits. The ‘new’ system generally represents the remainder of the city and does have existing treatment infrastructure (ie detention
basins) in place. However, the condition of the treatment infrastructure in the ‘new’
system is largely degraded due to construction site impacts and lack of a systematic
maintenance program. Generally, the ‘new’ system infrastructure requires an infusion of capital to tackle deferred maintenance items such as cleaning of storm pipes and detention ponds. Once complete, a normal O&M schedule can be returned to.
• The existing level of service of the stormwater utility, or stormwater management program prior to 2011 utility formation, has led to multiple MS4 permit recommendations for improvement, deficiencies, and one permit violation.
• The existing level of service of the stormwater utility has not effectively reduced the
frequency of exceeding the MS4 permitted water quality standards.
Staff will ask the Commission in its future policy decisions to address the identified deficiencies
of the stormwater utility by enhancing the level of service of the utility. Funding a level of
service for the stormwater utility that is suitable to eliminate future MS4 violations, improve
water quality, and remain generally compliant with permit criteria is recommended. During future policy discussions, staff will prepare several level of service options with concomitant
annual revenue requirements for Commission consideration. As the level of service of the utility
increases, it is generally observed that rates must increase as well in order to fund the additional
activities that create the higher level of service.
Staff will further recommend that the Commission establish a new rate assessment methodology
that assesses stormwater utility rates commensurate to stormwater system impacts. The current
assessment method is rudimentary, basing the stormwater utility rate on the size of the water
meter serving a property and has no foundation in system impact. At a future policy discussion,
staff can present several different rate assessment methods for Commission consideration and provide examples of rate changes to specific properties relative to the different methodologies.
ALTERNATIVES: As Suggested by the Commission.
FISCAL EFFECTS: Enhancing the level of service of the utility will create additional revenue needs to fund activities creating the enhanced level of service. Establishing policy concerning
level of service, and rate assessment methodology is beyond the scope of this special
presentation. Staff will return to the Commission in the near future with a formal policy
discussion to address these important policy considerations.
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Attachments:
Exhibit A: Overall Stormwater System Map (1 pg)
Exhibit B: Detention Basin Condition Assessment Form (1 pg) Exhibit C: Detention Basin Condition Analysis Map (1 pg)
Exhibit D: Gravity Main Structure Analysis Map (1 pg)
Exhibit E: MS4 Permit (41 pgs) Exhibit F: MS4 Audit Report (28 pgs) Exhibit G: Illicit Discharge Detection and Elimination Map (1 pg)
Exhibit H: MS4 Water Quality Monitoring Results (1 pg)
Report compiled on: 02/24/14
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§¨¦90
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19THMAIN 7THDURSTON
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HUFFINE ROUSEKAGY
COLLEGE
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Legend
!Manholes
Lateral Lines
Gavity Mains
Bozeman Waterways
Detention Ponds
0 0.75 1.50.375 Miles
¯
This Map was created by the City of Bozeman GIS Department on 3/14/2013.
City of Bozeman Stormwater System
Mapped Infrastructure as of 2/19/2014- 3,059 Inlets - 1,276 Manholes- 366 Detention Basins - 551 Outfalls- 93.43 Miles of Pipe Line - 86 Chases- 50 Screens - 300 Culverts- 21.6 Miles of Waterways - 14 Wells
±
This map was created on 2/19/2014 by the City of Bozeman GISDepartment and is intended for planning purposes only.
0 10.5 Miles
Exhibit A:
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Exhibit B:
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Figure 1 - Results from the 2013 city-wide detention pond and gravity main condition analysis.
Figure 4 – Cracked Underground Pipe
Figure 3 - Sediment Filled Gravity Main
Figure 2 –Clogged Detention Pond Outlet
Structure Exhibit C:105
Figure 10 - Punctured Stormwater Pipe
Figure 11 - Shifted Pipe Segment
Figure 12 – Cracked Pipe Section
Figure 9 - Results of the 2013 underground pipe assessment. Exhibit D:106
Exhibit E:
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Figure 5 - Map displaying all pollution sources responded to in 2013.
Figure 7 - Paint Spill
Figure 6 – Polluted Stormwater Entering
Bozeman Creek
Figure 8 – Pollution in Pipe from Cross-
Connection Exhibit G:176
Compiled MS4 Stormwater Sampling Data
City of Bozeman
Permit Identification Number: MTR040002
Reporting Period: January 1, 2013 – December 31, 2013
*Red numbers represent concentrations over permitted levels.
* ND = No Detection
Exhibit H:
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